News stories about
Vermillion County
Vermillion Reports is a news site about Vermillion County, Indiana. Our first article is about Wabash Valley Resource’s carbon sequestration project. We plan to publish articles on other topics. If you would like email notices about new articles, please send your email address to us at vermillionreports@gmail.com
WVR plans to truck CO2 to injection wells in Vermillion and Vigo counties, which will intensify the use of the injection sites. One question is: does the intensified use comply with local zoning?
By Larry Gavin
Wabash Valley Resources (WVR) is planning to develop a facility in West Terre Haute, Vigo County Indiana to produce 500,000 tons of anhydrous ammonia fertilizer each year. One by-product of the process is carbon dioxide which WVR plans to capture, liquify, and provide to its subsidiary Wabash Carbon Services (WCS). WVR or WCS will transport the liquified carbon dioxide (CO2) to two injection wells, one in Vermillion County and one in Vigo County, Indiana. WCS will use the wells to inject 1.67 million tons of CO2 into the ground each year for 12 years. So, a total of 20 million tons. The CO2 will be permanently stored in rock formations about 5,000 feet underground.
WVR and WCS initially planned to transport the CO2 to the injection wells through pipelines buried underground. But there has apparently been a change of plan. Instead of transporting the CO2 through underground pipelines, WCS now plans to transport the CO2 from its Terra Haute facility to the injection wells in Vermillion and Vigo counties by using heavy duty electric trucks with hydrogen fuel cells. The new plan is laid out in an Environmental Assessment of the project published by the U.S. Department of Energy (DOE) in August 2025 (the “report”). A link to the report is provided below. *
Three employees of WVR are listed as some of the many preparers of the report.
The Trucking Routes
The trucking route from WVR’s Terra Haute facility to the site of the injection well in Vermillion County, Site #1, is about 19 miles long, and the return route to the facility is about 9 miles. So, the round trip is about 28 miles. Report,11.
The route from the Terre Haute facility to the injection well in Vigo County is about 4.1 miles and the return trip to the facility is about 5.3 miles. The round trip is about 9.4 miles. Id.
A map showing the truck routes that is contained in DOE’s report is reprinted above.
Truck traffic
The truck traffic will be significant. The trucks delivering the CO2 to the Vermillion County site will be semi-trucks with 48-foot trailers and a total length of 68.5 feet. They will be capable of transporting up to 25 tons (50,000 pounds) of CO2 per trip, and have a gross weight of 80,000 pounds. Report, 34.
The trucks delivering CO2 to the Vigo County site will be up to 38 feet long, but still capable of transporting up to 25 tons of CO2 per trip and have a gross weight of 80,000 pounds. Id.
The report says, “It is anticipated that there would be approximately four or five round trips each hour in each CO2 injection well site. These operations would occur 24 hours a day, 7 days a week.” Report, 56
For residences that are on roads where trucks pass by on both the inbound and the outbound portions of the round-trip (i.e., portions of Stanford Avenue and State Road 63), there would be up to 10 truck pass-by events per hour (i.e, five trucks/hour x two-directional distribution). “This would equate to an average of approximately one truck passing a location every 6 minutes 24 hours a day, 7 days a week.” Report, 63.
For residences that are on roads used for only one leg of the inbound or outbound traffic, a truck would pass by about every 12 minutes, 24 hours a day, 7 days a week for 12 years. Id.
The Noise
The fleet of trucks will generate noise, although less than that generated by combustion engine trucks. Yet, there will be noise because road noise from tires, rather than the engine, is the primary source of noise from trucks, particularly at higher speeds. Report, 57, 62.
The report says there are 229 “noise-sensitive receptors” which are primarily rural and semi-rural single-family residences, within 500 feet of the trucking routes. Of the 229 noise sensitive receptors, 202 are associated with the route to CO2 injection well Site #,1 and 28 are associated with the route to CO2 injection well Site #2 (one receptor is associated with both routes). Report, 58.
The report provides a General Noise Table that provides the decibel levels of various types of commonly experience noises to provide some context for the noise levels. The examples are:
dBA Level
10 to 30: Breathing, whisper, rustling leaves, quiet rural area
30 to 50: Library, bird calls, quiet suburb, conversation at home
60: Conversation in a restaurant, background music, office (half as loud as 70 dB)
70: Vacuum cleaner, music or TV audio
80: Garbage disposal, food blender (2 times as loud as 70 dB)
90: Power mower, motorcycle at 25 feet (4 times as loud as 70 dB)
100: Garbage truck, jack hammer, farm tractor, motorcycle
The DOE report provides the estimated noise level of the passing trucks using two methods. One method “predicts the maximum noise level that would be received from a singular truck pass-by event.” Under this method, the noise level of the trucks would be 70 dBA for a residence at 50 feet of a non-highway (i.e. roads other than State Route 63); 60 dBA for a residence at 150 feet of a non-highway; and 54 dBA for a residence at 300 feet of a non-highway. Report, 63-64.
The noise levels for homes that are 50 feet and 150 feet from the roads are above 55 dBA, which exceeds the EPA’s recommended goal for a day-night sound level of 55 dBA or less for an exterior location. The noise level at homes that are more than 300 feet from the road is 54 dBA, which is just below the EPA recommended goal of 55 dBA or less. Report, 57, 63-64.
A second method of estimating the noise level of the trucks provides a single noise value that “represents the equivalent continuous sound level over a full 24-hour period as a single value that summarizes the cumulative noise exposure over an entire day and night.” Report, 63.
Using this measure, a residence within 500 feet along the northern route (non-highway) would experience a sound level between 39 and 54 dBA, Ldn; a residence within 500 feet along the southern route (non-highway) would experience a sound level between 38 and 51 dBA, Ldn; and a residence within 500 feet along State Route 63 would experience a sound level between 41 and 48 dBA, Ldn. Report, 63-64.
The DOE report concludes that no homes along the transportation routes “would be exposed to a 24-hour day-night noise level that would exceed 55 dBA, Ldn.” Report, 64.
The report says, “WVR has committed to consulting with Vermillion and Vigo Counties, as well as State of Indiana authorities, and would review and address any noise-related issues (see Appendix G). Given these consultations, WVR would implement applicable measures (e.g., install noise attenuation barriers along transportation routes, provide modifications to residences, modify truck operating schedules) to adhere to applicable regulatory standards or ordinances related to noise levels.
“Because of the commitment made by WVR to consult with local and state authorities, as well as commitments to implement applicable measures and adhere to applicable regulatory standards and ordinances, which may include collecting additional reference sound-level data to refine the predictive model and allow tailored noise-control measures, noise-related construction and operational impacts would not be significant.” Report, 66)
DOE’s report also assesses the noise level generated at the well site, which is not discussed here.
There is no indication that the DOE asked people residing in homes within 500 feet of a truck route whether or not they thought the truck traffic would impact their lives, the enjoyment of their homes, or the value of their homes.
Installations at and use of the injection sites
The site of the injection well in Vermillion County will cover about 17 acres. The site of the injection well in Vigo County will cover about 11 acres. Report, 17.
Each injection well site will include an 8-bay truck unloading rack mounted on a foundation. Each site will also include two storage (or surge) vessels, a boil off gas compression system, a refrigeration unit, CO2 pumps and an injection well. Report, 17, 24, 25, 28, 34.
A heavy-duty truck capable of transporting up to 25 tons of CO2 will come to the site every twelve minutes, 24 hours a day, seven days a week, for 12 years. The unloading operations will be performed by the truck drivers using a semi-automated system. Report, 28, 34.
The unloaded CO 2 will be transferred into two storage vessels that will provide “a buffer volume of CO2 between the unloading rack and the CO2 pumps.” The vessels will have a capacity of 317,000 gallons (1,100 metric tons) and be 60 feet long, with a diameter of 15 feet. The vessels will be mounted in a horizontal position to limit visual impacts. Report, 28, 34.
The truck unloading system and storage vessels will be equipped with a dedicated boil-off gas recompression system that will prevent CO2 emissions from escaping into the atmosphere at the CO2 injection well sites. Report, 28, 34.
A refrigeration unit will be designed to capture gaseous CO2 from the unloading rack and storage vessels and then compress and condense it back to a liquid, thereby preventing CO 2 emissions from the facility. Report, 28, 34.
Once the CO2 reaches the injection zone, it will achieve the pressure and temperature needed to move it to a supercritical, or dense, phase state. A centrifugal pump will provide the required pressure to the wellheads. Report, 28, 34.
There will be a wellhead to inject the CO2 about 5,000 feet into the ground. “The injection wells will be equipped with a full suite of pressure, temperature, and flow monitoring equipment, that will provide” an instantaneous indication of conditions in the injection zone, at the wellhead, and along the entire well string. Any deviation will result in alerts at the main control room; automated shutdowns will occur if critical conditions are exceeded.” Report, 25, 34.
Zoning of the injection sites
Vermillion County. The DOE report says that the zoning of the CO2 well injection site in Vermillion County is Zone A-1. Report, 112.
Section 1.08 of Vermillion County’s Unified Development Ordinance provides, “Except as hereafter allowed,” no structure shall be erected, nor shall any land be used except when in full compliance with all provisions” of the ordinance.
Vermillion County Zone A-1 is for “general agricultural operations.” Section 2.03 of the ordinance provides a long list of permitted uses:
“Accessory Permitted Uses
• agricultural tourism
• bio-diesel production ≤ 5,000 gallons per year with on-site consumption
• home business (type 1)
• home business (type 2)
• home business (type 3)
• roadside sales
• solar array (small)
• utility facility, above ground (small)
Agricultural Permitted Uses
• agricultural crop production
• agricultural crop production, greenhouse
• agricultural crop production, organic
• agricultural products, storage
• forestry
• land conservation
• orchard
• plant nursery, wholesale
• raising of farm animals
• stable (private)
• tree farm, wholesale
• vineyard
Institutional Permitted Uses
• cemetery or mausoleum
Residential Permitted Uses
• dwelling, single-family detached
Temporary Permitted Uses
Seasonal sale of farm produce [TU-02].”
The ordinance also provides for Special Exception Uses. But Section 9.10 A provides that a special use must be permitted by the Board of Zoning Appeals.
Although the Vermillion County Unified Development Ordinance was adopted on April 1, 2025, the county previously had a zoning ordinance that provided for an agricultural zoning district and that specified permitted and special uses.
Vigo County Zoning. The DOE report says that the CO2 injection well site in Vigo County is in the Zone A-1 Agricultural District. Report, 112.
Sections 1.K and 5 A.1 of Vigo County’s Unified Zoning Ordinance provide that no building or structure may be erected on land and that no land may be used unless it conforms to the provisions of the ordinance.
The A-1 zoning in Vigo County permits “the production of grain or livestock; stables; forest or tree production; pasture; setting aside land in a government set-aside reserve program; a farmstead; dwellings for caregivers, care receivers or caretakers; uses accessory to agricultural operations on the site; or, uses accessory to agricultural operations in the area.” Section 8.01.B.
The ordinance provides a special exception for mobile homes. But Section 5 provides that the Board of Appeals must approve a special exception.
The DOE report does not comment on whether WVR’s planned uses of the well sites comply with the zoning laws of Vermillion and Vigo counties. But it does not appear that the ordinances permit an eight-truck unloading dock for CO2, the storage vessels, and the other equipment that WVR plans to construct or install and use at the site.
In a post on the website of the Indiana Department of Natural Resources, David Bausman, General Counsel of IDNR, says, “Local government says where it [carbon sequestration] can be done, and state/federal government says how it can be done.” He adds, “IC 14-39 does not preempt local units of government from adopting zoning ordinances regarding the siting of CCS projects.”
Thus, according to Mr. Bausman’s comments, IC 14-38 does not preempt Vermillion and Vigo Counties zoning ordinances regarding the siting of WVR’s carbon sequestration project. **
On Monday, Sept. 29, the author of this article asked a representative of WVR if WVR’s proposed use of the sites in Vermillion and Vigo counties was a permitted use, and if so to explain how it was a permitted use; if the WVR’s proposed use was a special use, and if so to explain how, and if WVR had applied for and obtained approval of a special use; and if WVR maintained that the Vermillion and Vigo county zoning ordinances did not apply to WVR for any reason and if so to explain why. The author asked for a response by the end of business on Thursday.
The representative of WVR said he was traveling and would not be able to have any responses from WVR by Thursday.
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Footnotes
*The Environmental Assessment referred to in the text was prepared as a necessary step to provide WVR with a loan guarantee pursuant to the U.S. Department of Energy (DOE) Title XVII Clean Energy Financing Program. Under Title XVII, the Secretary of Energy is authorized to provide loan guarantees for projects that support clean energy deployment and energy infrastructure reinvestment in the United States. The decision as to whether to provide a loan guarantee (federal financial assistance) constitutes a major federal action, which requires DOE to conduct an environmental review under the National Environmental Policy Act (NEPA) of 1969, as amended (42 U.S.C. 4321–4347). In its environmental assessment, the DOE found that the loan guarantee would have no significant impact on the human environment. This finding was premised in part on WVR’s commitment to take certain actions to mitigate certain potential effects. Report, 117.
** Chapter 1 of Indiana Code 14-39 is a special law that authorizes carbon sequestration in Indiana. See 14-39-1 et seq. Section 14-39-1-5 provides:
“(a) This chapter authorizes the establishment of a carbon sequestration pilot project:
(1) that will:
(A) capture carbon dioxide at the proposed ammonia plant to be located at 44 West Sandford Avenue, West Terra Haute, Indiana’
(B) construct, operate, or use not more than two (2) carbon dioxide pipelines;
(C) maintain operations only in Vigo and Vermillion counties; and
(D) inject the carbon dioxide underground through one (1) or more injection wells pursuant to a Class VI well permit issued by the United States Environmental Protection Agency; and
(2) that will employ the underground storage of carbon dioxide as an alternative to releasing the carbon dioxide into the air.”
Nothing in this section requires that the injection wells or the injection sites be placed in specific locations in Vermillion or Vigo counties, and nothing requires that an injection well be placed in Vermillion County.
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Links to references:
Environmental Assessment for the Wabash Valley Resources LLC Wabash Hydrogen Energy Center Project, prepared by the Department of Energy Loan Guarantee Program, August 2025: https://www.energy.gov/sites/default/files/2025-08/EA-2301_Wabash_Vally_Resources_August2025.pdf
Vermillion County Unified Development Ordinance: Vermillion-UDO-Final-1.pdf
Unified Zoning Ordinance for Vigo County, Indiana: https://www.vigocounty.in.gov/egov/documents/1088861399_472198.pdf
Carbon Capture and Sequestration (CCS) in Indiana, Indiana Department of Natural Resources, David Bausman, General Counsel:
Links to other related articles in Vermillion Reports:
“Taking a look at the constitutionality of the law authorizing Wabash Valley Resources’ CO2 project”: https://vermillionreports.org/laws-concerning-c02-project
“Analysis and Viewpoint: The public was short-changed in the EPA public hearing and comment period on Wabash Carbon Services’ CO2 permits”: https://vermillionreports.org/public-shortchanged-epa-public-hearings
“Analysis: New report concludes that storing CO2 deep underground in rock formations containing brine is too risky,”: https://vermillionreports.org/new-report-concludes-that-storing-co2-deep-underground-in-rock-formations-containing-brine-is-too-risky